FCC adds foreign-made power inverters and advanced robotic devices to Covered List

The Federal Communications Commission (FCC) issued a Public Notice on July 28, 2026, adding foreign-produced power inverters and advanced robotic devices to its Covered List, which prohibits the authorization and importation of new device models.

The decision follows national security determinations issued on July 27, 2026 by a White House-convened executive branch interagency body, which found that foreign-produced power inverters and advanced robotic devices pose an unacceptable risk to national security.

While the notice does not impact the sale, import, or usage of power inverters and advanced robotic devices previously approved through the FCC’s equipment authorization process, the decision has significant implications for equipment manufacturers, energy companies, robotics firms, and enterprises that depend on these products. Because most radiofrequency devices, including power inverters and advanced robotic devices, require the FCC’s authorization before they may be imported, marketed, or sold in the United States, placement on the Covered List effectively bars new foreign-produced models from entering the US market.

The determination includes an exemption pathway for producers of foreign-made power inverters and advanced robotic devices to apply for Conditional Approval of their devices. Applications for Conditional Approval must include a detailed, time-bound plan to onshore manufacturing to the US. Conditionally approved devices would be exempt from the Covered List restrictions and could continue to receive FCC equipment authorization. Applicants who are granted Conditional Approval must provide ongoing quarterly progress updates on their on-shoring plan. The Department of War (DoW) or Department of Homeland Security (DHS) will evaluate such submissions for power inverters, but only DoW will evaluate such submissions for advanced robotic devices.

The FCC’s Office of Engineering and Technology (OET) also released a companion Public Notice detailing a “limited waiver” of the Commission’s rules to permit previously authorized power inverters and advanced robotic devices to continue receiving software and firmware updates, including security patches and vulnerability fixes, at least until January 1, 2029.

In this alert, we provide an overview of the updates to the Covered List and discuss practical implications.

Background

The FCC’s Covered List was established by the Secure and Trusted Communications Networks Act of 2019 and identifies communications equipment and services deemed to pose an unacceptable risk to US national security or the safety and security of US persons. By operation of the FCC’s rules, equipment placed on the Covered List is prohibited from receiving new FCC equipment authorizations.

The FCC’s public notice follows the two national security determinations transmitted to the FCC on July 27, 2026. Both determinations state that foreign-produced power inverters and advanced robotic devices pose unacceptable risks to the United States by “facilitating a supply chain vulnerability that could disrupt U.S. economic security, including sectors critical to national security,” and “creat[ing] a cybersecurity risk that threatens the security of critical infrastructure and the safety of U.S. persons.”

Foreign produced

The FCC notice applies to “foreign produced” power inverters and advanced robotic devices, and it incorporated the definition of “domestic end product” from the Buy American statute to define “foreign produced.” The FCC notice applies to equipment that would not qualify as a “domestic end product” under the Buy American statute. Under that statute, the article must be manufactured in the US, and the cost of domestic components must exceed 65 percent of the cost of all components for items delivered in calendar years 2024 through 2028, 75 percent for items delivered in 2029, and 60 percent for items delivered in 2030 and beyond.

Power inverters

The first national security determination defines “power inverter” for purposes of the Covered List as a bi-directional power device or system that converts direct current electricity to alternating current electricity or converts alternating current electricity to direct current electricity, and which contains components that enable remote communication, control, sensing, data collection, or monitoring through Wi-Fi, cellular, Bluetooth, or other similar connections. Microinverters, string inverters, central inverters, and hybrid (battery-based) inverters qualify as power inverters.

In addressing the risks posed by foreign-produced power inverters, the determination focuses on the “lack of a secure U.S. supply chain for inverters and the continuous inflow of foreign-produced or controlled inverters and inverter components.” In addition, the determination finds that inverters’ remote connectivity introduces additional vulnerabilities on the US grid which “could enable foreign firms to turn off the inverters or use them to collect and exfiltrate data, facilitate remote access and surveillance by foreign government actors, or be otherwise exploited through a cyberattack.”

Advanced robotic devices

The second national security determination includes a detailed definition of “advanced robotic devices” and explains that such devices’ networked capabilities “create extensive vulnerabilities and vectors for attacks that can manipulate the data and physical operation of the advanced robotic system.” The devices also “collect data that could be leveraged by malign actors to surveil Americans, enhance the capabilities of foreign intelligence services, or to remotely commandeer the robots.”

Conditional Approval process

The Covered List designation includes an exemption pathway for producers of foreign-made power inverters and advanced robotic devices to apply for Conditional Approval of their devices. Conditionally approved devices would be exempt from the Covered List restrictions and could continue to receive FCC equipment authorization. For power inverters, either the DoW or DHS will evaluate submissions. For advanced robotic devices, only the DoW will evaluate submissions.

Conditional Approvals require detailed disclosures regarding corporate structure, manufacturing and supply chain information, and time-bound plans to establish or expand US-based manufacturing. If the FCC receives a further specific determination from the DoW or DHS that a given power inverter or advanced robotic device, or class of such devices, does not pose an unacceptable risk, it will further update the Covered List.

Unlike the Conditional Approval established for consumer-grade routers, which expires after 18 months, the Conditional Approval established for power inverters and advanced robotic devices remains valid as long as the device or class of devices is determined by the relevant national security agency not to pose an unacceptable risk.

Scope and practical implications

This update to the Covered List generally prohibits new foreign-produced power inverters and advanced robotic devices from being imported, marketed, or sold in the US. However, it does not prohibit the import, sale, or use of existing models of such devices. The action does not affect previously purchased devices, nor does it affect sales to or use by the federal government or federal agencies. Producers of advanced robotic devices and power inverters that receive Conditional Approval from the DoW or DHS can continue to receive FCC equipment authorizations.

A pattern of expansion to categorical prohibitions

The latest additions to the Covered List mark a significant shift toward identifying entire product categories of foreign-made devices and components, rather than naming individual manufacturers.

When the FCC first published the Covered List in March 2021, it focused on specific entities whose equipment was found to pose national security risks. The FCC first adopted the device-wide approach in December 2025, when it added all Uncrewed Aircraft Systems (UAS) and UAS critical components produced in a foreign country, with limited exceptions. The FCC took a similar approach when it added foreign-made consumer-grade routers to the Covered List in March 2026. The router determination also includes a Conditional Approval process to exempt routers from Covered List restrictions that closely tracks with the process set forth for power inverters and advanced robotic devices.

With the addition of power inverters and advanced robotic devices, the FCC has now applied this categorical approach to four distinct product categories in less than eight months, signaling that further expansions may be forthcoming.

Going forward

The FCC has released a FAQ page on the latest Covered List designations and guidance on submissions for Conditional Approval for power inverters and advanced robotic devices.

DLA Piper is closely monitoring developments in this area and further updates to the Covered List and has experience assisting businesses with securing Conditional Approval from the FCC. For more information regarding these new requirements, please contact the authors or your DLA Piper attorney.